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we agree with respondent.6 On that record, we find that respon-
dent has satisfied respondent’s burden of production under
section 7491(c) with respect to the additions to tax at issue in
these cases. Petitioners have the burden of establishing that
they are not liable for those additions to tax. See Higbee v.
Commissioner, 116 T.C. 438, 446-447 (2001). Mr. Dimon testified
that he did not file a return for 1996 because some unidentified
person advised him that the $127,970 that he received during 1996
represented proceeds from the sale of a business, and not earned
income. We shall not rely on Mr. Dimon’s general, conclusory,
and uncorroborated testimony as to the reasons why he did not
file a return for 1996 or pay estimated tax for that year. On
the record before us, we find that petitioners have failed to
show that they are not liable for the additions to tax under
sections 6651(a)(1) and 6654 that respondent determined in the
respective notices issued to them.
We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing,
Decisions will be entered under
Rule 155.
6The record establishes that neither Ms. Dimon nor Mr. Dimon
filed a return for taxable year 1996 and that neither of them
made any estimated or other tax payments for that year except for
$94 which was withheld from Ms. Dimon’s wages.
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